Being diligent

Engaging other firms to enhance your proposition can really help set you apart from others and enable you to offer better technology, a faster service, or just simply get more customers. As with any new arrangement that commits your firm or clients it is always about investing time up front to make sure you don't have regrets later on or at least are able to upgrade your arrangements when the time comes.


This comes down to due diligence: how many of us can remember the old days when we used to think that the fact a firm is regulated means it isn't necessary to check the client onboarding processes or the financial position of the firm? Sadly, these days you only have to glance at the stream of skilled person reviews going on for financial crime compliance or the cancellation of permissions for firms not meeting Threshold Conditions to know that simply being regulated is no longer a substitute for doing your own due diligence.


Plus we now also know that in light of our recent experiences with Covid-19 that we have to keep business continuity checks high up on the due diligence checklist and keep those under regular review along with our initial due diligence. These service review meetings are great for deepening relationships as well as nipping issues in the bud.


So the various consultations on Outsourcing and Operational Resilience that remain open for comment until 1 October 2020 are proposing new rules to tell us perhaps what we should already be doing, but in a much more prescriptive way that could mean some detailed changes to agreements, internal policies, and even building registers when the new rules come out next year. Meanwhile making time to be clear about where your arrangements sit against today's requirements and briefing your SMF for Outsourcing (usually the SMF24) will be time well spent.

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